The Group regularly conducts mapping exercises to identify and assess corruption risks. Led at the most appropriate levels of the organisation, mapping is a collaborative process that takes into account the specific context of the business and the country. The resulting maps are used to prioritise identified risks and define adapted action plans to improve risk management. The aim is to provide complete coverage of the Group’s activities.
To manage corruption risks, the Group deploys:
The Group is engaged in a continuous improvement approach relating to its risk management systems, which involves regular updates and reinforcement of the measures in place.
(a) Prevention measures
Dissemination and acceptance of the Code of Ethics and Conduct and the Anti-corruption Code of Conduct. All Group employees and all its stakeholders have access to the Code of Ethics and Conduct and the Anti-corruption Code of Conduct, which are available on the Group’s website and its intranet.
The Group has also issued a recommendation and implemented an IT tool to structure the dissemination of the Code of Ethics and Conduct and the Anti-corruption Code of Conduct to targeted employees and their acceptance of these codes. The Group’s recommendation is to distribute these two documents to the main responsible parties, comprising at a minimum senior executives, operational and functional executives, and specific managers including those responsible for specific agencies and activities, projects, procurement, human resources, accounting and finance. However, each business line remains free to identify a wider target group for the dissemination and acceptance of the codes.
At 31 December 2025, more than 91,000 active employees had electronically signed and accepted the Code of Ethics and Conduct and the Anti-corruption Code of Conduct. For information, the Group currently has just over 61,000 managers.
Assessment of the integrity of third parties. The Group has issued a recommendation for business units to define and implement procedures that assess the integrity of third parties. In line with the corruption risk map, this process takes place at the most appropriate levels of the organisation.
Employee training. Training and information are key factors for implementing the Group’s business ethics policy. To enable all employees to effectively contribute to preventing and detecting corruption, depending on their duties and responsibilities, specific training programmes are developed and rolled out at each of the Group’s organisational levels. This training complements the general e-learning modules on the Group platform – which include “Anti-corruption – Challenges and Risks” and “Conflicts of Interest” – and are designed to help employees understand the related domestic legal framework, but also the international one where applicable, and identify the issues and responsibilities involved. They explain the corruption scenarios identified and the risks involved, the steps to be taken to reduce these risks, the recommended behaviours when faced with solicitations and the procedures for reporting inappropriate conduct, as well as the disciplinary actions that may be taken or the criminal penalties that may apply to individuals for any infringement of rules or regulations. As exemplary managerial behaviour is essential to effectively spearhead ethical practices within its subsidiaries, VINCI’s conduct guidelines are covered in all of the management training programmes provided by the Group’s Academy structures.
Anti-corruption training is aimed at all VINCI Group managers and all employees exposed to risks of corruption and influence-peddling.
This involves at a minimum:
